E and M, Re

����������� Prior to the implementation of the Children Order an unmarried father was not a parent for the purposes of the Adoption Order and his agreement to either the adoption of his child or the freeing of the child for adoption was not required under that Order or dispensed with by the Court.� The grounds upon which a Court can dispense with the agreement of a parent are set out in Article 16(2) of the Adoption Order as amended:

����������� Social Services were also attempting to engage Mr S in a psychological assessment.� He had attended one session at the Children's Resource Team but declined to attend further as he did not consider it necessary.� On 5 November 1997 he agreed to attend a psychologist but would not guarantee his attendance because of his substantial work commitment.

����������� It identified the emotional abuse which Mrs McA's children by her marriage experienced as �

1)�������� a parent relationship which was characterised by poor communication, frequent rows with verbal and physical abuse and alcohol abuse;

2)�������� Mrs McA feeling pressurised as the main carer with very little support from her husband in parenting the children and no other social supports;